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Home Recordkeeping & Recording Requirements

Recordkeeping & Recording Requirements

Did you know that March 2nd, is the deadline to electronically submit your OSHA Form 300A for the previous calendar year?  

OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Covered establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this Final Rule.

Remember, not all establishments are covered by this requirement. Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to send their information to OSHA.  Remember, these criteria apply at the establishment level, not to the firm as a whole.

  • The establishment’s peak employment during the previous calendar year was 19 or fewer, regardless of the establishment’s industry.
  • The establishment’s industry is on this list, regardless of the size of the establishment.
  • The establishment had peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on this list.

For a full list of exempted industries, visit the Occupational Safety and Health Administration (OSHA) webpage.  

Record Keeping Requirements

Employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses.  (Certain low-risk industries are exempted).  Minor injuries requiring first aid only DO NOT need to be recorded.   

  • How does OSHA define a recordable injury or illness?
  • How does OSHA define first aid?

This information helps employers, workers, and OSHA evaluate the safety of a workplace, understand industry hazards, and implement worker protections to reduce and eliminate hazards — preventing future workplace injuries and illnesses.  

Maintaining and Posting Records

Records must be maintained at the worksite for at least five (5) years.  Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year.  Also, if requested, copies of the records must be provided to current and former employees, or their representatives.  

  • Get recordkeeping forms 300, 300A, 301, and additional instructions.
  • Read the full OSHA Recordkeeping regulation (29 CFR 1904).

Updated Electronic Submission of Records

The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you can provide the Agency your OSHA Form 300A information.  The date by which certain employers are required to submit to OSHA the information from their completed Form 300A is March 2nd of the year after the calendar year covered by the form.  

How does OSHA define a recordable injury or illness?

How does OSHA define first aid? 

  • Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes). 
  • Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin.
  • Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment). 
  • Using hot or cold therapy;
  • Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
  • Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
  • Using eye patches; 
  • Removing foreign bodies from the eye using only irrigation or a cotton swab;
  • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
  • Using finger guards;
  • Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
  • Drinking fluids for relief of heat stress.

This information helps employers, workers, and OSHA evaluate the safety of a workplace, understand industry hazards, and implement worker protections to reduce and eliminate hazards, thereby preventing future workplace injuries and illnesses.  

Maintaining and Posting Records 

Records must be maintained at the worksite for at least five years.  Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year.  Also, if requested, copies of the records must be provided to current and former employees, or their representatives. Get recordkeeping forms and additional instructions 

Updated Electronic Submission of Records — What does it require? 

The new rule, which took effect Jan. 1, 2017, requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms. Analysis of this data will enable OSHA to use its enforcement and compliance assistance resources more efficiently. Some of the data will also be posted to the OSHA website. OSHA believes that public disclosure will encourage employers to improve workplace safety and provide valuable information to workers, job seekers, customers, researchers and the general public. The amount of data submitted will vary depending on the size of company and type of industry.

How will electronic submission work?

OSHA has provided a secure website that offers three options for data submission. First, users are able to manually enter data into a webform. Second, users are able to upload a CSV file to process single or multiple establishments at the same time. Last, users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface). The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you are able to provide the Agency your OSHA Form 300A information. The date by which certain employers are required to submit to OSHA the information from their completed annual Form 300A is July 1 of the following year.

Severe Injury Reporting 

Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours. Learn more about reporting online or by phone.

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